subject:"Are these Business Associates"

RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Jason Brege

As a
Business Associate collection agency, we have not had any Covered Entity clients
request to track our disclosures themselves. The wording they have used
inour contractsinstructs us to forward disclosure information if
they notify us of an accounting request. What we are doing is recording
our relevant disclosures on our information system, and upon request we will
forward them to the client when an accounting isrequested for a certain
patient. For a BA like a collection or billing agency, I would imagine
that these types of requests will be fairly common, since we hold a lot of the
patient's information. I believe this is the most straightforward way to
go, but a Covered Entity should make sure the BA knows what types of disclosures
to record, andthatmight be adaunting task with some BAs.

Thanks,

Jason
Brege
Clinton A. Harkins, P.C.

-Original Message-From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]Sent: Tuesday, March 11, 2003 6:43
AMTo: WEDI SNIP Privacy Workgroup ListSubject: Tracking
Disclosures by Business AssociatesI am
curious how covered entities are tracking accountings of disclosures by
business associates that they then have to provide to the patient. In some
ways, this seems like a daunting task but then again, I am not sure how often
it will come up... I would appreciate your thoughts.Jill Rubin,
Esq.(617)388-2404[EMAIL PROTECTED]
---
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Re: Tracking Disclosures by Business Associates

2003-03-11 Thread JillGWlaw

By the same token, for the patient accounting, would you have to include disclosures you make to business associates like transcription agencies and disposal agencies? They would come up very often...

Jill Rubin, Esq.
(617)388-2404
[EMAIL PROTECTED]
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RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Jason Brege

I'm
not entirely sure who "you" is in your question, but I assumed that you are
asking about business associates disclosing to business associates,so
here's a stab at an answer. It might also apply if you're asking about CE
disclosures to transcription/disposal agencies.

I
believe a business associate would have toaccount forthose
disclosures to other business associates where the disclosure is not for
treatment, payment, or healthcare operations purposes. Given our nature as
a collection agency, most (if not all) of our disclosures are exempt from
accounting because they are for payment purposes. If we had a
transcription service, it could possibly need accounting, but I think that could
be absorbed under payment purposes. It would depend on what type of
service they are providing. The disposal agency is not TPO as far as I can
determine, but if you're having them shred the information onsite,
trainedas a member of your workforce, it becomes a use rather than a
disclosure. The only information taken offsite is shredded paper which
formerly contained PHI.Thus nothing would be accounted for in the
case of the disposal agency working onsite. Offsite, I think it would need
further investigation. If we were a BA that had the practice of disclosing
information to public health authorities or other organizations, then we would
definitely have to account for those. I think the best assessment is to
determine whether the BA is disclosing for TPO purposes or otherwise, and then
direct them to account for the non-TPO disclosures that would be accounted for
if done directly by the Covered Entity.
Thanks,

Jason
Brege
Clinton A. Harkins, P.C.

---
The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time.

RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Joanne.Marquez

Title: Message

Wouldn't disposal come under operations? We have a vendor who picks us
locked bins of documents to be shredded. We have had them sign a Business
Associate Agreement (we are also Business Associates.) I would not think
there would be a need for accounting for these pick ups to be logged as
disclosures.

Joanne
Marquez
Senior Director

Beech Street
Corporation
Account Services
(949)
672-1519

-Original Message-From: Jason Brege
[mailto:[EMAIL PROTECTED] Sent: Tuesday, March 11, 2003 7:32 AMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Tracking Disclosures by Business Associates
I'm
not entirely sure who "you" is in your question, but I assumed that you are
asking about business associates disclosing to business associates,so
here's a stab at an answer. It might also apply if you're asking about
CE disclosures to transcription/disposal agencies.

I
believe a business associate would have toaccount forthose
disclosures to other business associates where the disclosure is not for treatment, payment, or healthcare operations purposes. Given our nature
as a collection agency, most (if not all) of our disclosures are exempt from
accounting because they are for payment purposes. If we had a
transcription service, it could possibly need accounting, but I think that
could be absorbed under payment purposes. It would depend on what type
of service they are providing. The disposal agency is not TPO as far as
I can determine, but if you're having them shred the information onsite, trainedas a member of your workforce, it becomes a use rather than a
disclosure. The only information taken offsite is shredded paper which
formerly contained PHI.Thus nothing would be accounted for in the
case of the disposal agency working onsite. Offsite, I think it would
need further investigation. If we were a BA that had the practice of
disclosing information to public health authorities or other organizations,
then we would definitely have to account for those. I think the best
assessment is to determine whether the BA is disclosing for TPO purposes or
otherwise, and then direct them to account for the non-TPO disclosures that
would be accounted for if done directly by the Covered
Entity.
Thanks,

Jason Brege
Clinton A. Harkins, P.C.

-Original Message-From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]Sent: Tuesday, March 11, 2003 9:44
AMTo: [EMAIL PROTECTED];
[EMAIL PROTECTED]Subject: Re: Tracking Disclosures by
Business AssociatesBy the same token, for the
patient accounting, would you have to include disclosures you make to business associates like transcription agencies and disposal agencies? They
would come up very often...Jill Rubin,
Esq.(617)388-2404[EMAIL PROTECTED]
---The WEDI SNIP listserv to which you are subscribed
is not moderated. The discussions on this listserv therefore represent the
views of the individual participants, and do not necessarily represent the
views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an
official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and
services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time.You are
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RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Jason Brege

Title: Message

I
would have originally thoughtdisposal was operationsas well, but
when I looked at the definition of healthcare operations in 164.501, it really
seemed likea stretch. It doesn't fitinto any of the 6 main
areas under this definition: 1.Quality assessment and improvement activities,
2.Reviewing the competence or qualifications of health care professionals,
3.Underwriting, 4.Medical review/fraud and abuse, 5.Business planning and
development, 6.Business management. The only place to squeeze it in would
be Business Management, but shredding documents doesn't seem to really fit with
the 5 "included but not limited to" examples under that part. It really
just depends on your legal counsel and how your risk assessments see this
issue. Practically, I think it would be absolutely insane to account for
every piece of PHI on every piece of paper that you destroy. I think there
are ways to justify this as Business Management, and I think your documentation
of this decision would be key. I believe this is one reason why
mostentities have just brought shredders or shredding companies
onsite.

Thanks,

Jason
Brege
Clinton A. Harkins, P.C.

-Original Message-From:
[EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]Sent: Tuesday, March 11,
2003 11:18 AMTo: [EMAIL PROTECTED];
[EMAIL PROTECTED]Subject: RE: Tracking Disclosures by
Business Associates
Wouldn't disposal come under operations? We have a vendor who picks us
locked bins of documents to be shredded. We have had them sign a
Business Associate Agreement (we are also Business Associates.) I would
not think there would be a need for accounting for these pick ups to be logged
as disclosures.

Joanne
Marquez
Senior Director

Beech Street
Corporation
Account
Services
(949)
672-1519

-Original Message-From: Jason Brege
[mailto:[EMAIL PROTECTED] Sent: Tuesday, March 11, 2003 7:32
AMTo: WEDI SNIP Privacy Workgroup ListSubject: RE:
Tracking Disclosures by Business Associates
I'm not entirely sure who "you" is in your question, but I assumed
that you are asking about business associates disclosing to business
associates,so here's a stab at an answer. It might also apply if
you're asking about CE disclosures to transcription/disposal
agencies.

I
believe a business associate would have toaccount forthose
disclosures to other business associates where the disclosure is not for
treatment, payment, or healthcare operations purposes. Given our
nature as a collection agency, most (if not all) of our disclosures are
exempt from accounting because they are for payment purposes. If we
had a transcription service, it could possibly need accounting, but I think
that could be absorbed under payment purposes. It would depend on what
type of service they are providing. The disposal agency is not TPO as
far as I can determine, but if you're having them shred the information
onsite, trainedas a member of your workforce, it becomes a use rather
than a disclosure. The only information taken offsite is shredded
paper which formerly contained PHI.Thus nothing would be
accounted for in the case of the disposal agency working onsite.
Offsite, I think it would need further investigation. If we were
a BA that had the practice of disclosing information to public health
authorities or other organizations, then we would definitely have to account
for those. I think the best assessment is to determine whether the BA
is disclosing for TPO purposes or otherwise, and then direct them to account
for the non-TPO disclosures that would be accounted for if done directly by
the Covered Entity.
Thanks,

Jason Brege
Clinton A. Harkins, P.C.

Re: medical vendors as Business Associates

2003-02-28 Thread Doug Webb




David,
Amen!
I would much rather have a clear answer beforehand 
thanenforcement afterword.

The opinions expressed here are my own and not necessarily the opinion of 
LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary 
Hospital  Health Care Centers[EMAIL PROTECTED]

"This electronic message may contain information that is confidential 
and/or legally privileged. It is intended only for the use of the individual(s) 
and entity(s) named as recipients in the message. If you are not an 
intended recipient of the message, please notify the sender immediately, 
delete the material from any computer, do not deliver, distribute, or copy this 
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  - Original Message - 
  From: 
  David Frenkel 
  To: WEDI SNIP Privacy Workgroup List 
  
  Sent: Thursday, February 27, 2003 11:18 
  PM
  Subject: RE: medical vendors as Business 
  Associates
  
  
  Doug,
  This is another 
  example of the daunting enforcement task CMS has. There are so many interconnected 
  issues that have no clear resolution. 
  Somebody should calculate the cost of the lack of clarity of 
  HIPAA.
  
  Regards,
  
  
  David 
  Frenkel
  Business 
  Development
  GEFEG 
  USA
  Global 
  Leader in Ecommerce Tools
  www.gefeg.com
  612-237-1966
  -Original 
  Message-From: Doug Webb 
  [mailto:[EMAIL PROTECTED]] Sent: Wednesday, February 26, 
  2003 4:00 
  PMTo: WEDI SNIP Privacy Workgroup 
  ListSubject: Re: medical 
  vendors as Business Associates
  
  
  David,
  
  I would also tend to lean that way. 
  Could we get a definitive answer "From 
  Above"?
  
  
  
  The opinions expressed here are my own 
  and not necessarily the opinion of LCMH.
  
  
  
  Douglas M. WebbComputer System 
  EngineerLittle Company of Mary Hospital  Health Care Centers[EMAIL PROTECTED]
  
  
  
  "This electronic message may contain 
  information that is confidential and/or legally privileged. It is intended 
  only for the use of the individual(s) and entity(s) named as recipients 
  in the message. If you are not an intended recipient of the message, please 
  notify the sender immediately, delete the material from any computer, do 
  not deliver, distribute, or copy this message, and do not disclose its 
  contents or take action in reliance on the information it contains. Thank 
  you."
  
  
  
  
  

- Original Message - 


From: David Frenkel 


To: WEDI SNIP Privacy Workgroup 
List 

Sent: 
Wednesday, February 
26, 2003 02:55 
PM

Subject: RE: 
    medical vendors as Business Associates


Doug,
This 
discussion has appeared on other healthcare listservs and there seems to be 
a strong leaning towards having medical device manufacture reps be 
considered part of TPO. 
It brings up an interesting liability issue as well as a patient 
consent issue for reps being in the OR.

Regards,


David 
Frenkel
Business 
Development
GEFEG 
USA
Global 
Leader in Ecommerce Tools
www.gefeg.com
612-237-1966
-Original 
Message-From: Doug 
Webb [mailto:[EMAIL PROTECTED] Sent: Wednesday, February 26, 
2003 2:53 
PMTo: David Frenkel; WEDI SNIP Privacy 
Workgroup ListSubject: Re: 
    medical vendors as Business Associates


David,

They do, but I'm not directly involved, 
so I don't know the answer to your 
question.



Jim Hewitt did bring up an interesting 
point that these vendors may also be hardware/software support people. 
In that role, I would think that a BAA would be appropriate to state that 
they would protect PHI they contact while maintaining the 
equipment.



I had been thinking just of their role 
as a supplier of the equipment.

Whew! Covering all bases is 
tough!.



The opinions expressed here are my own 
and not necessarily the opinion of LCMH.



Douglas M. WebbComputer System 
EngineerLittle Company of Mary Hospital  Health Care Centers[EMAIL PROTECTED]



"This electronic message may contain 
information that is confidential and/or legally privileged. It is intended 
only for the use of the individual(s) and entity(s) named as 
recipients in the message. If you are not an intended recipient of the 
message, please notify the sender immediately, delete the material 
from any computer, do not deliver, distribute, or copy this message, and do 
not disclose its contents or take action in reliance on the information it 
contains. Thank you."





  
  - Original Message - 
  
  
  From: David Frenkel 
  
  
  To: WEDI SNIP Privacy

Re: medical vendors as Business Associates

2003-02-27 Thread Doug Webb

Jo,
quite so.
I would lkie to call an
entity that would be a CE if they did a single electronic transaction that a
standard has been established for a "Potential Covered Entity" (PCE) and avoid
all the repeated verbiage.
Any takers?

The opinions expressed here are my own and not necessarily the opinion of
LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary
Hospital Health Care Centers[EMAIL PROTECTED]

"This electronic message may contain information that is confidential
and/or legally privileged. It is intended only for the use of the individual(s)
and entity(s) named as recipients in the message. If you are not an
intended recipient of the message, please notify the sender immediately,
delete the material from any computer, do not deliver, distribute, or copy this
message, and do not disclose its contents or take action in reliance on the
information it contains. Thank you."

- Original Message -
From:
Jo Clair
To: 'Doug Webb'
Sent: Wednesday, February 26, 2003 04:17
PM
Subject: RE: medical vendors as Business
Associates

Not all providers are CE's
(they may not do electronic transactions).

-Original Message-From: Doug Webb
[mailto:[EMAIL PROTECTED]Sent: Wednesday, February 26, 2003 1:57
PMTo: WEDI SNIP Privacy Workgroup ListSubject: Re:
medical vendors as Business Associates
Craig,
That would be my
understanding.

The opinions expressed here are my own and not necessarily the opinion
of LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary
Hospital Health Care Centers[EMAIL PROTECTED]

"This electronic message may contain information that is confidential
and/or legally privileged. It is intended only for the use of the
individual(s) and entity(s) named as recipients in the message. If you
are not an intended recipient of the message, please notify the sender
immediately, delete the material from any computer, do not deliver,
distribute, or copy this message, and do not disclose its contents or take
action in reliance on the information it contains. Thank you."

- Original Message -
From:
Craig
Moen
To: 'Doug Webb'
Sent: Wednesday, February 26, 2003
03:28 PM
Subject: RE: medical vendors as
Business Associates

Doug-

I want to make sure I am
understanding.
We are a home health
agency that provides therapy services. Our therapists interact with
DME providers, andorthotists and obviously share PHI. Since
these are outside services not provided by us, the DME providers, and
orthotist independently bill the appropriate insurance company. They
would then also be CE's and then we would be able to share info with them
without a BAA because information can be shared between CE's as a
part of treatment.
Correct?

Thanks for your
input

Craig
Moen
Director of
Rehabilitation
THERAPY
2000
Dallas,
TX---The WEDI SNIP listserv to which
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Re: medical vendors as Business Associates

2003-02-26 Thread Doug Webb




Jill,
I agree with Dan.

The critical question is do you do anything on behalf of a 
Covered Entity that involves PHI? If this answer is "No", you do not need 
a BAA.

Providing devices to non-patients isolates you from 
PHI.

Providing devices to patients is acting on behalf of yourself 
(I assume you make a profit on the deal, or you wouldn't be in business), not a 
service to the Covered Entity. If you also bill insurance carriers 
electronically, you may be a Covered Entity (providing Treatment).

As Dan said, it would be extremely rare that a vendor of this 
type would be in a Business Associate relationship with a Covered 
Entity.

If it operates in some other role in addition to being a DME 
vendor, that role must be considered independantly.
.
The opinions expressed here are my own and not necessarily the opinion of 
LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary 
Hospital  Health Care Centers[EMAIL PROTECTED]

"This electronic message may contain information that is confidential 
and/or legally privileged. It is intended only for the use of the individual(s) 
and entity(s) named as recipients in the message. If you are not an 
intended recipient of the message, please notify the sender immediately, 
delete the material from any computer, do not deliver, distribute, or copy this 
message, and do not disclose its contents or take action in reliance on the 
information it contains. Thank you."



  - Original Message - 
  From: 
  Dan Kelsey 
  
  To: WEDI SNIP Privacy Workgroup List 
  
  Sent: Wednesday, February 26, 2003 08:32 
  AM
  Subject: RE: medical vendors as Business 
  Associates
  
  I think your 
  decision would have to be very fact based. For example, if a wheelchair 
  company sells 50 wheelchairs to a hospital, then they would not be a BA of the 
  hospital. However, if the hospital rehab unit orders a custom fit 
  wheelchair that involves disclosure of the patient's limitations, physical 
  build, etc., then chances are a BA relationship does not exist either. I 
  say "chances are" because treatment by a health care provider is exempt from 
  the BA definition and a BAA is not required. 
  
  The key issue 
  is if the medical vendor meets the definition of a health care provider - 
  there is a mention in HIPAA for the Federal definition, and it is fairly all 
  encompassing. Generally speaking, I do not think the majority of these 
  vendors would be business associates.
  
  Hope this 
  helps,
  
  Dan Kelsey Practice Advisor Indiana State 
  Medical Association 800-257-4762 
  (317) 261-2060 (317) 261-2076 - fax 
  
-Original Message-From: [EMAIL PROTECTED] 
[mailto:[EMAIL PROTECTED]Sent: Wednesday, February 26, 2003 7:42 
AMTo: WEDI SNIP Privacy Workgroup ListSubject: medical 
vendors as Business AssociatesAre 
medical vendors that supply products like prosthesis, wheelchairs, etc., 
considered BA? I have been researching this and can't seem to come up with 
clear answer...Thanks in advanceJill Rubin, 
Esq.(617)388-2404[EMAIL PROTECTED] ---The WEDI SNIP 
listserv to which you are subscribed is not moderated. The discussions on 
this listserv therefore represent the views of the individual participants, 
and do not necessarily represent the views of the WEDI Board of Directors 
nor WEDI SNIP. If you wish to receive an official opinion, post your 
question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. 
These listservs should not be used for commercial marketing purposes or 
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  necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. 
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  products and services. They also are not intended to be used as a forum for 
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Re: medical vendors as Business Associates

2003-02-26 Thread Doug Webb




Dawn,
This looks like a lot of "CYA" BAA contracts being sent 
unnecessarily. The logic seems to be send them to everybody, and see who 
signs them.

Don't forget that the CE is the one who is responsible to 
ensure that the proper BAAs are in place. Since a contract is signed by 
both sides, it doesn't matter who drafts the text. A BA who drafts the BAA 
text is trying to increase the likelyhood that their version is the one that is 
signed. Don't sign anything until your lawyer checks it out!

The opinions expressed here are my own and not necessarily the opinion of 
LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary 
Hospital  Health Care Centers[EMAIL PROTECTED]

"This electronic message may contain information that is confidential 
and/or legally privileged. It is intended only for the use of the individual(s) 
and entity(s) named as recipients in the message. If you are not an 
intended recipient of the message, please notify the sender immediately, 
delete the material from any computer, do not deliver, distribute, or copy this 
message, and do not disclose its contents or take action in reliance on the 
information it contains. Thank you."



  - Original Message - 
  From: 
  Dawn 
  Lenox 
  To: Doug Webb 
  Sent: Wednesday, February 26, 2003 09:37 
  AM
  Subject: Re: medical vendors as Business 
  Associates
  
  I tried to explain this to 
  a vendor that sent us (CE) their BA (non-CE) as a favor to usThey said we 
  were being liberal in our interpretation and that they were being 
  "conservative"...they did not even request that we sign it...go 
  figure.
  
- Original Message - 
From: 
Doug Webb 
To: WEDI SNIP Privacy Workgroup 
List 
Sent: Wednesday, February 26, 2003 9:29 
AM
Subject: Re: medical vendors as 
Business Associates

Jill,
I agree with Dan.

The critical question is do you do anything on behalf of a 
Covered Entity that involves PHI? If this answer is "No", you do not 
need a BAA.

Providing devices to non-patients isolates you from 
PHI.

Providing devices to patients is acting on behalf of 
yourself (I assume you make a profit on the deal, or you wouldn't be in 
business), not a service to the Covered Entity. If you also bill 
insurance carriers electronically, you may be a Covered Entity (providing 
Treatment).

As Dan said, it would be extremely rare that a vendor of 
this type would be in a Business Associate relationship with a Covered 
Entity.

If it operates in some other role in addition to being a 
DME vendor, that role must be considered independantly.
.
The opinions expressed here are my own and not necessarily the opinion 
of LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary 
Hospital  Health Care Centers[EMAIL PROTECTED]

"This electronic message may contain information that is confidential 
and/or legally privileged. It is intended only for the use of the 
individual(s) and entity(s) named as recipients in the message. If you 
are not an intended recipient of the message, please notify the sender 
immediately, delete the material from any computer, do not deliver, 
distribute, or copy this message, and do not disclose its contents or take 
action in reliance on the information it contains. Thank you."



  - Original Message - 
  From: 
  Dan 
  Kelsey 
  To: WEDI SNIP Privacy Workgroup 
  List 
  Sent: Wednesday, February 26, 2003 
  08:32 AM
      Subject: RE: medical vendors as 
  Business Associates
  
  I think 
  your decision would have to be very fact based. For example, if a 
  wheelchair company sells 50 wheelchairs to a hospital, then they would not 
  be a BA of the hospital. However, if the hospital rehab unit orders 
  a custom fit wheelchair that involves disclosure of the patient's 
  limitations, physical build, etc., then chances are a BA relationship does 
  not exist either. I say "chances are" because treatment by a health 
  care provider is exempt from the BA definition and a BAA is not 
  required. 
  
  The key 
  issue is if the medical vendor meets the definition of a health care 
  provider - there is a mention in HIPAA for the Federal definition, and it 
  is fairly all encompassing. Generally speaking, I do not think the 
  majority of these vendors would be business 
associates.
  
  Hope this 
  helps,
  
  Dan Kelsey Practice Advisor Indiana State 
  Medical Association 800-257-4762 (317) 
  261-2060 (317) 261-2076 - fax 
  
  
-Original Message-From: [EMAIL PROTECTED] 
[mailto:[EMAIL PROTECTED]Sent: Wednesday, February 26, 2003 
7:42 AMT

RE: medical vendors as Business Associates

2003-02-26 Thread David Frenkel










Doug,

Does your facility do medical device
implants? If so, do you know what the official
position is of your facility on this? Thanks.



Regards,





David Frenkel

Business Development

GEFEG USA

Global Leader in
Ecommerce Tools

612-237-1966



-Original Message-
From: Doug Webb
[mailto:[EMAIL PROTECTED]] 
Sent: Wednesday, February 26, 2003 11:29 AM
To: WEDI SNIP Privacy Workgroup
List
Subject: Re: medical vendors as
Business Associates





Vicki,





I believe
that in this case the vendor would a Healthcare Providerparticipating in
Treatment.They would not be a BA. They would be a CE if they used
any of the standard electronic transactions.











The
opinions expressed here are my own and not necessarily the opinion of LCMH.











Douglas
M. Webb
Computer System Engineer
Little Company of Mary Hospital  Health Care Centers
[EMAIL PROTECTED]











This
electronic message may contain information that is confidential and/or legally
privileged. It is intended only for the use of the individual(s) and
entity(s) named as recipients in the message. If you are not an intended
recipient of the message, please notify the sender immediately, delete
the material from any computer, do not deliver, distribute, or copy this
message, and do not disclose its contents or take action in reliance on the
information it contains. Thank you.




















-
Original Message - 





From: Vicki
Schaff 





To: Doug Webb 





Sent: Wednesday, February
26, 2003 10:53 AM





Subject: Re:
medical vendors as Business Associates











Consider the vendor who supplies anew
medical deviceto ahealthcare facility (CE)and the
vendorprovides instruction to a surgeon (CE)during implantation of
the device. The vendor has access to PHI.One legal
opinion has stated that thevendor is a BA of the healthcare
facility. Your Comments. 







-
Original Message - 





From: Doug Webb






To: WEDI
SNIP Privacy Workgroup List 





Sent: Wednesday, February
26, 2003 9:29 AM





Subject: Re:
medical vendors as Business Associates











Jill,





I
agree with Dan.











The
critical question is do you do anything on behalf of a Covered Entity that
involves PHI? If this answer is No, you do not need a BAA.











Providing
devices to non-patients isolates you from PHI.











Providing
devices to patients is acting on behalf of yourself (I assume you make a profit
on the deal, or you wouldn't be in business), not a service to the Covered
Entity. If you also bill insurance carriers electronically, you may be a
Covered Entity (providing Treatment).











As Dan
said, it would be extremely rare that a vendor of this type would be in a
Business Associate relationship with a Covered Entity.











If it
operates in some other role in addition to being a DME vendor, that role must
be considered independantly.





.





The
opinions expressed here are my own and not necessarily the opinion of LCMH.











Douglas
M. Webb
Computer System Engineer
Little Company of Mary Hospital  Health Care Centers
[EMAIL PROTECTED]











This
electronic message may contain information that is confidential and/or legally
privileged. It is intended only for the use of the individual(s) and
entity(s) named as recipients in the message. If you are not an intended
recipient of the message, please notify the sender immediately, delete
the material from any computer, do not deliver, distribute, or copy this
message, and do not disclose its contents or take action in reliance on the
information it contains. Thank you.




















-
Original Message - 





From: Dan
Kelsey 





To: WEDI
SNIP Privacy Workgroup List 





Sent: Wednesday, February
26, 2003 08:32 AM





Subject: RE:
medical vendors as Business Associates











I think your decision
would have to be very fact based. For example, if a wheelchair company
sells 50 wheelchairs to a hospital, then they would not be a BA of the
hospital. However, if the hospital rehab unit orders a custom fit
wheelchair that involves disclosure of the patient's limitations, physical
build, etc., then chances are a BA relationship does not exist either. I
say chances are because treatment by a health care provider is exempt
from the BA definition and a BAA is not required. 











The key issue is if the
medical vendor meets the definition of a health care provider - there is a
mention in HIPAA for the Federal definition, and it is fairly all
encompassing. Generally speaking, I do not think the majority of these
vendors would be business associates.











Hope this helps,





Dan Kelsey 
Practice Advisor 
Indiana State Medical Association 
800-257-4762 
(317) 261-2060 
(317) 261-2076 - fax 





-Original
Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
Sent: Wednesday, February 26, 2003
7:42 AM
To: WEDI SNIP Privacy Workgroup
List
Subject: medical vendors as
Business Associates

RE: medical vendors as Business Associates

2003-02-26 Thread David Frenkel










Doug,

This discussion has appeared on other healthcare
listservs and there seems to be a strong leaning
towards having medical device manufacture reps be considered part of TPO. It
brings up an interesting liability issue as well as a patient consent issue for
reps being in the OR.



Regards,





David Frenkel

Business Development

GEFEG USA

Global Leader in
Ecommerce Tools

www.gefeg.com

612-237-1966



-Original Message-
From: Doug Webb [mailto:[EMAIL PROTECTED]] 
Sent: Wednesday, February 26, 2003 2:53 PM
To: David Frenkel; WEDI SNIP
Privacy Workgroup List
Subject: Re: medical vendors as
Business Associates





David,





They do, but I'm not directly involved, so I don't
know the answer to your question.











Jim Hewitt did bring up an interesting point that
these vendors may also be hardware/software support people. In that role,
I would think that a BAA would be appropriate to state that they would protect
PHI they contact while maintaining the equipment.











I had been thinking just of their role as a supplier
of the equipment.





Whew! Covering all bases is tough!.











The opinions expressed here are my own and not
necessarily the opinion of LCMH.











Douglas M. Webb
Computer System Engineer
Little Company of Mary Hospital  Health Care Centers
[EMAIL PROTECTED]











This electronic message may contain information that
is confidential and/or legally privileged. It is intended only for the use of
the individual(s) and entity(s) named as recipients in the message. If
you are not an intended recipient of the message, please notify the sender
immediately, delete the material from any computer, do not deliver,
distribute, or copy this message, and do not disclose its contents or take
action in reliance on the information it contains. Thank you.




















- Original Message - 





From: David Frenkel 





To: WEDI
SNIP Privacy Workgroup List 





Sent: Wednesday, February 26, 2003 02:10 PM





Subject: RE: medical
vendors as Business Associates









Doug,

Does your facility do
medical device implants? If so, do you
know what the official position is of your facility on this? Thanks.



Regards,





David
Frenkel

Business
Development

GEFEG USA

Global
Leader in Ecommerce Tools

612-237-1966



-Original Message-
From: Doug Webb
[mailto:[EMAIL PROTECTED] 
Sent: Wednesday, February 26, 2003 11:29 AM
To: WEDI SNIP Privacy Workgroup
List
Subject: Re: medical vendors as
Business Associates





Vicki,





I believe
that in this case the vendor would a Healthcare Providerparticipating in
Treatment.They would not be a BA. They would be a CE if they used
any of the standard electronic transactions.











The
opinions expressed here are my own and not necessarily the opinion of LCMH.











Douglas
M. Webb
Computer System Engineer
Little Company of Mary Hospital  Health Care Centers
[EMAIL PROTECTED]











This
electronic message may contain information that is confidential and/or legally privileged.
It is intended only for the use of the individual(s) and entity(s) named
as recipients in the message. If you are not an intended recipient of the
message, please notify the sender immediately, delete the material from
any computer, do not deliver, distribute, or copy this message, and do not
disclose its contents or take action in reliance on the information it
contains. Thank you.




















-
Original Message - 





From: Vicki
Schaff 





To: Doug Webb 





Sent: Wednesday, February
 26, 2003 10:53 AM





Subject: Re:
medical vendors as Business Associates











Consider the vendor who supplies anew
medical deviceto ahealthcare facility (CE)and the
vendorprovides instruction to a surgeon (CE)during implantation of
the device. The vendor has access to PHI.One
legal opinion has stated that thevendor is a BA of the healthcare facility.
Your Comments. 







-
Original Message - 





From: Doug Webb






To: WEDI
SNIP Privacy Workgroup List 





Sent: Wednesday, February
 26, 2003 9:29 AM





Subject: Re:
medical vendors as Business Associates











Jill,





I
agree with Dan.











The
critical question is do you do anything on behalf of a Covered Entity that
involves PHI? If this answer is No, you do not need a BAA.











Providing
devices to non-patients isolates you from PHI.











Providing
devices to patients is acting on behalf of yourself (I assume you make a profit
on the deal, or you wouldn't be in business), not a service to the Covered
Entity. If you also bill insurance carriers electronically, you may be a
Covered Entity (providing Treatment).











As Dan
said, it would be extremely rare that a vendor of this type would be in a
Business Associate relationship with a Covered Entity.











If it
operates in some other role in addition to being a DME vendor, that role must
be considered independantly.





.





The
opinions

Re: medical vendors as Business Associates

2003-02-26 Thread Doug Webb

Craig,
That would be my
understanding.

The opinions expressed here are my own and not necessarily the opinion of
LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary
Hospital Health Care Centers[EMAIL PROTECTED]

- Original Message -
From:
Craig
Moen
To: 'Doug Webb'
Sent: Wednesday, February 26, 2003 03:28
PM
Subject: RE: medical vendors as Business
Associates

Doug-

I want to make sure I am
understanding.
We are a home health agency
that provides therapy services. Our therapists interact with DME
providers, andorthotists and obviously share PHI. Since these are
outside services not provided by us, the DME providers, and orthotist
independently bill the appropriate insurance company. They would then
also be CE's and then we would be able to share info with them without a BAA
because information can be shared between CE's as a part of
treatment.
Correct?

Thanks for your
input

RE: medical vendors as Business Associates

2003-02-26 Thread Rachel Foerster




It's more likelythis activity/role falls under a 
DME provider activity and thus may make this function/role a provider type. If 
they then seek reimbursement from a payer/health plan, this constitutes acting 
as a provider, doesn't it?

I'm aware of at least one major orthopaedic mfgr that 
has already determined its activity in directly providing to the patient their 
DME classified products and for which they then submit a claim for reimbursement 
makes this activity/role a covered entity.



Rachel 
Foerster CEO  
PresidentRachel 
Foerster  Associates, Ltd. Professionals in Health 
Care EDI, Privacy  Security39432 North Avenue 
Beach Park, IL 60099 Voice: 
847-872-8070 Fax: 847-872-6860 eMail: 
[EMAIL PROTECTED] 
http://www.rfa-edi.com 
##
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Access by anyone else is unauthorized. Any unauthorized reader is hereby 
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and may be unlawful. If you 
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you

  -Original Message-From: [EMAIL PROTECTED] 
  [mailto:[EMAIL PROTECTED]Sent: Wednesday, February 26, 2003 6:42 
  AMTo: WEDI SNIP Privacy Workgroup ListSubject: medical 
  vendors as Business AssociatesAre 
  medical vendors that supply products like prosthesis, wheelchairs, etc., 
  considered BA? I have been researching this and can't seem to come up with 
  clear answer...Thanks in advanceJill Rubin, 
  Esq.(617)388-2404[EMAIL PROTECTED] ---The WEDI SNIP 
  listserv to which you are subscribed is not moderated. The discussions on this 
  listserv therefore represent the views of the individual participants, and do 
  not necessarily represent the views of the WEDI Board of Directors nor WEDI 
  SNIP. If you wish to receive an official opinion, post your question to the 
  WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs 
  should not be used for commercial marketing purposes or discussion of specific 
  vendor products and services. They also are not intended to be used as a forum 
  for personal disagreements or unprofessional communication at any 
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  the list, please use the Subscribe/Unsubscribe form at 
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RE: Are dieticians Business Associates?

2003-02-25 Thread Matthew Rosenblum

Vikas,

If the dietary purpose is treatment (including evaluations and assessments
for food-intake, medication contraindications, etc.) the dietician would NOT
be defined under HIPAA as a business associate.  However, if the dietary
purpose is related to say, a quality improvement activity (defined under
HIPAA as a health care operation), then the possibility exists for the
dietician to be defined as a business associate.
 
I hope that this helps.
 
Your questions are always welcome.
 
Matt
 
Matthew Rosenblum
Chief Operations Officer
Privacy, Quality Management  Regulatory Affairs
http://www.CPIdirections.com

CPI Directions, Inc.
10 West 15th Street, Suite 1922
New York, NY 10011
 
(212) 675-6367
[EMAIL PROTECTED]
 
CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the
individual or entity to which it is addressed and may contain information
that is privileged, confidential and exempt from disclosure under applicable
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distribute it.  Please notify the sender by E-Mail at the address shown and
delete the original message. Thank you.
 
AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del
individuo o la entidad a la cual se dirige y puede contener información
privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si
usted ha recibido esta comunicación por error, por favor no lo distribuya.
Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el
mensaje original. Gracias.
 
-Original Message-
From: Vikas Budhiraja [mailto:[EMAIL PROTECTED] 
Sent: Tuesday, February 25, 2003 11:52 AM
To: WEDI SNIP Privacy Workgroup List
Subject: Are dieticians Business Associates?

A question about Dieticians. If a contract dietician reviews a patient's
medical charts for dietary purposes, is he/she considered a BA? Or would
this be considered part of treatment.

Thanks,
Vikas



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of Directors nor WEDI SNIP. If you wish to receive an official opinion, post
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on this listserv therefore represent the views of the individual participants, and do 
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you wish to receive an official opinion, post your question to the WEDI SNIP Issues 
Database at http://snip.wedi.org/tracking/.   These listservs should not be used for 
commercial marketing purposes or discussion of specific vendor products and services.  
They also are not intended to be used as a forum for personal disagreements or 
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RE: Board of Directors - Workforce or Business Associates?

2003-01-16 Thread Leslie C Bender










How are
organizations classifying Board of Directors or Trustee members? Workforce -- or since they are not
under the direction of the covered entity, but have a need from
time to time, to receive PHI, or might they better be classified as business
associates and need a business associate agreement?

Leslie C.
Bender 

General
Counsel/Privacy Official 
The ROI Companies 
1922
  Greenspring Drive, Suite 7 
Timonium, Maryland 21093 












---
The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/.   These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services.  They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time.

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RE: Board of Directors - Workforce or Business Associates?

2003-01-16 Thread Matthew Rosenblum












Leslie,



A
Corporation's charter and bylaws would control how the Board may
function. Consequently, the Board could be construed as part of the
workforce.



Further,
in the Preamble to the (initial) Final Privacy rules, HHS notes that,
independent contractors may or may not be workforce members.
However, for compliance purposes we will assume that such personnel are members
of the workforce if no business associate contract exists.



I hope that this helps.



Your questions are always welcome.



Matt



Matthew
Rosenblum

Chief Operations Officer

Privacy, Quality Management 
Regulatory Affairs

http://www.CPIdirections.com



CPI Directions, Inc.

10 West 15th Street, Suite 1922

New York, NY 10011



(212) 675-6367

[EMAIL PROTECTED]



CONFIDENTIALITY
NOTICE: This E-Mail is intended only for the use of the individual or entity to
which it is addressed and may contain information that is privileged,
confidential and exempt from disclosure under applicable law. If you have
received this communication in error, please do not distribute it. Please
notify the sender by E-Mail at the address shown and delete the original
message. Thank you.



AVISO DEL
CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener
informacin privilegiada, confidencial y exenta de acceso bajo la ley
aplicable. Si usted ha recibido esta comunicacin por error, por favor
no lo distribuya. Favor notificar al remitente del E-Mail a la
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-Original Message-
From: Leslie C Bender
[mailto:[EMAIL PROTECTED]] 
Sent: Thursday,
 January 16, 2003 4:12 PM
To: WEDI SNIP Privacy Workgroup
List
Cc: 'Drexler, Deborah (EHS)'
Subject: RE: Board of Directors -
Workforce or Business Associates?



How are organizations classifying Board of Directors
or Trustee members? Workforce -- or since they are not under the
direction of the covered entity, but have a need from time to time, to
receive PHI, or might they better be classified as business
associates and need a business associate agreement?

Leslie C. Bender 

General Counsel/Privacy Official 
The ROI Companies 
  1922 Greenspring Drive, Suite 7
 
  Timonium, Maryland 21093 









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Are these Business Associates

2003-01-13 Thread rahul singh

Are the following busness associates:

Contract Social workers
Contract physical therapists and dieticians
Funeral Homes

Thanks





_
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RE: Tracking Disclosures by Business Associates

Re: Tracking Disclosures by Business Associates

RE: Tracking Disclosures by Business Associates

RE: Tracking Disclosures by Business Associates

RE: Tracking Disclosures by Business Associates

Re: medical vendors as Business Associates

Re: medical vendors as Business Associates

Re: medical vendors as Business Associates

Re: medical vendors as Business Associates

RE: medical vendors as Business Associates

RE: medical vendors as Business Associates

Re: medical vendors as Business Associates

RE: medical vendors as Business Associates

RE: Are dieticians Business Associates?

RE: Board of Directors - Workforce or Business Associates?

RE: Board of Directors - Workforce or Business Associates?

Are these Business Associates

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